AQCS Environmental: Environmental Compliance News

San Diego APCD Revises EVR Permit Deadline

2008-03-13T12:27:00.000-07:00

In a memo dated 2/28/2008 and distributed by email on 3/05/2008, the San Diego County Air Pollution Control District (SDAPCD), stated that the deadline to submit permit applications for Enhanced Vapor Recovery (EVR) installation has been moved back to 10/01/2008. The memo further stated that the reason for the change was, "...to allow GDF operators more time to evaluate Phase II Enhanced Vapor Recovery (EVR) systems currently certified and other systems which may be certified prior to the revised application submittal deadline."

The memo also provided guidance for ISD installation permits, stating that permit applications should be submitted at least six months prior to the installation deadline for In-Station-Diagnositcs (ISD).

Facilities that dispense more than 1.8 million gallons/year must install ISD before 09/01/2009 and facilities that dispense between 600,000 and 1.8 million gallons/year must install ISD before 09/01/2010.

The full text of the memo can be found here: http://airqualitycs.com/EVRDeadline.pdf

CARB Urges Local Air Districts to Give EVR Exemptions for ORVR and E-85

2008-02-27T18:42:00.000-08:00

In a letter dated 2/20/2008, the CARB Executive Officer, James Goldstene, urged local Air District Control Officers to rewrite local vapor recovery rules to allow exemptions from Enhanced Vapor Recovery (EVR) installation at sites that have captive fleets with on-road refueling vapor recovery (ORVR) or dispense E-85. The recommendations are in line with a memo provided by the US EPA. The letter and supporting attachments can be found here: http://airqualitycs.com/e85orvrletter022008.pdf. The CARB and the US EPA's rationale for this policy change is simple: if the vast majority of vehicles that are fueled at a filling facility are equipped with ORVR, then phase 2 vapor recovery is redundant and provides no emission reductions. In the case of E-85, CARB staff has estimated that less than 0.10 tons of ozone producing VOCs will be released by the operation of E-85 dispensers with no phase 2 vapor recovery. On October 22nd, I wrote about the San Diego APCD's plan to implement phase 2 vapor recovery exemptions at ORVR and E-85 sites. The changes recommended by CARB are essentially identical with the planed rule changes proposed by the SDAPCD. That article can be found here: http://airqualitycs.blogspot.com/2007_10_01_archive.html#1865506486205554569
It contains useful information on how to determine if a vehicle is ORVR equipped.

All Portable Diesel Engines Must be Tier Certified by 2010

2008-02-15T10:29:00.000-08:00

The deadline to replace older, non-tier certified portable engines with new, cleaner engines is less than two years away. the California Air Toxics Control Measure (ATCM) that regulates portable engine emissions can be found in 17 CCR 93116. It states:
"all portable diesel-fueled engines shall be certified to meet a federal or California standard for newly manufactured nonroad engines pursuant to 40 CFR Part 89 or Title 13 of the California Code of Regulations (that is, certified to Tier 1, 2 or 3 nonroad engine standards)"

the full text of the regulation can be found here: 17 CCR 93116 http://www.arb.ca.gov/portable/perp/peatcm091207.pdf.

However, the same regulation also mandates fleet emission levels with deadlines in 2013, 2017 and 2020. The 2013 fleet standard is 0.3 g/bhp-hr. If you are planning on replacing older non-Tier engines with used Tier 1 and 2 engines, you may then have to replace them again in 2013 to achieve fleet compliance standards. AQCS advises purchasing the highest engine tier available before 2010.

Table of fleet emission standards and deadlines:

Table of Tier 1, 2, 3 and 4 emission standards and phase-in dates:

Portable Diesel Engine Reports are Due on March 1, 2008

2008-02-15T10:15:00.000-08:00

Owners and operators of portable diesel engines registered with the California Air Resources Board (CARB) under the Portable Equipment Registration Program (PERP) must submit an annual usage report on or before March 1, 2008. The report must include the registration number, the locations of operation, and the hours of operation or gallons of fuel used. This form can be found at: http://www.arb.ca.gov/portable/perp/records/form28rev1.pdf.

Additional PERP forms can be found at: http://www.arb.ca.gov/portable/perp/records.htm.

The PERP regulation is part of the California Code of Regulations, Title 13, 2450. The entire text of the regulation can be found at: 13 CCR 2450 http://www.arb.ca.gov/portable/perp/perpreg091207.pdf

Comparison of Franklin Fueling and Vapor System Technologies Phase II EVR Systems: Which System Provides the Best Value

2008-02-01T08:53:00.000-08:00

California State Law requires the installation of Phase II Enhanced Vapor Recovery (EVR) equipment at nearly all gasoline-dispensing facilities (GDF) statewide on or before April 1, 2009. As of February 2007, approximately 13,000 GDFs had not conducted the required installation. Currently there are only two systems available that meet the requirements of Phase II EVR: the Franklin Fueling System, manufactured by Franklin Electric and the Vapor System Technologies system, manufactured by Vapor System Technologies, Inc. The following report discusses the relative merits of each system in order to provide guidance to GDF operators in selecting which system to purchase. In summary, it appears that the Franklin Fueling Systems is superior. The reasons that the Franklin Fueling System is best are numerous: Franklin Fueling is the only system that is currently certified for GDFs that dispense more than 600,000 gallons/year. It has a greater supply of certified installation technicians, lower cost of installation, lower parts costs, and lower testing costs than the Vapor System Technologies system. Detailed explanations of each evaluation category are included in the following document:
http://airqualitycs.com/AQCS_EVR_EVAL_0219_CAPX.pdf

Balance EVR System Approved by CARB

2007-11-30T08:48:00.000-08:00

The California Air Resources Board (CARB) has approved the Vapor Systems Technology (VST) Phase 2 Enhanced Vapor Recovery (EVR) System. The system is based on the balance principle (the vapor exchange between vehicle fuel tank and gas station fuel storage system is achieved through positive displacement). The system is not currently approved for In-Station Diagnostics (ISD), which will be required in 2009 for facilities that dispense more than 600,000 gallons of gasoline per year.

The VST system utilizes an electric pump-driven membrane vapor processor to virtually eliminate vapor losses from the vapor vent line. Operators who install this system should expect to see reductions in inventory losses through evaporation.

The VST system is one of only two systems certified by the state as Phase 2 EVR compliant. It is also the only balance system certified to date. The deadline for EVR installation for most facilities will be in April 2009. Because no other systems are currently certified, existing gasoline stations will most likely need to choose between the VST system and the Healy system.

Listed below are some of the operational parameters required for compliance for the VST system:

Flow rate must be between 6 and 10 gallons per minute
Maximum hose length of hose and breakaway combination cannot exceed 15 feet
System must be installed with liquid removal hoses
Breakaways are not reconnecting and must be replaced after a drive-off
Components reused after a drive-off must be tested before returned to service
No flow limiters are allowed in the system
Operators must maintain records of vapor processor alarms and maintenance
The system must be maintained as directed by the VST Installation , Operation and Maintenance Manual

Additional operational parameters can be found in the CARB Executive Order: http://www.arb.ca.gov/vapor/eos/eo-vr203/vr203a.pdf

Operators who choose to install the VST system will be required to conduct the following tests:

Liquid Removal
Hydrocarbon Sensor Verification
Vapor Pressure Sensor Verification Test
Determination of VST Processor Activation Pressure
Nozzle Bag Test
Additional tests as dictated by the Phase 1 system

On November 27th, CARB released an approval letter allowing the installation of VST hanging hardware as replacement parts for existing (non-EVR) balance equipped gasoline stations. This will allow operators to replace with parts that will be compliant with the VST EVR in anticipation of eventual conversion.

Attention: Forklift Fleet Operators

2007-11-04T19:02:00.000-08:00

By Ms. Erin Sheehy and Ms. Rosalie Skefich

After California Air Resources Board (CARB) dropped a proposed ban of all but zero-emission forklifts, a revised rule was recently adopted and became effective May 12, 2007. The final rule, commonly referred to as "Off-Road Large Spark-Ignition Engines" applies to older units [13 CCR, Article 2, Section 2775] and newer units [13 CCR, Article 4.5, Section 2430] produced on or after January 1, 2001.

Off-road large spark-ignition (LSI) equipment subject to the rule are mobile sources greater than 25 horsepower and >1 liter engine displacement that are powered by gasoline, liquefied petroleum gas (LPG) aka propane, and other alternate fuels. Typical applications that use LSI engines include forklifts, airport ground support, sweepers, scrubbers, large turf care equipment, portable generators, and industrial tow tractors.

In accordance with the regulations, fleet operators in California, defined as 4 or more units, are required to complete a baseline inventory of their forklift and nonforklift units within 6 months of rule adoption. This baseline inventory is due by November 10, 2007. The inventory must include equipment type, make, model, serial number, and emission certification standards or retrofit verification level. Fleet operators must also maintain on file a written statement, product delivery ticket or receipt from the fuel supplier stating that the fuel supplied meets all applicable state and federal laws for use in their engines. Inventories must be maintained on-site until 2016.

By January 1, 2009, initial reductions for fleet average emissions for large forklift fleets, medium forklift fleets and non-forklift fleets must be met either by retrofitting, replacing, or retiring the engine. Two CARB-verified retrofit kits are currently available. Additional lower fleet average emission standards are required for 2011 and 2013. Some exemptions from the requirements are available for limited use, rented and leased equipment, and military tactical vehicles.For more information, visit the CARB website. For consulting assistance in identifying exempt equipment, establishing fleet average emissions, assessing appropriate retrofit kits, and complying with future emissions standards, contact , Ms. Erin Sheehy, ECS, 310-664-1396.

CARB Amends Portable Diesel Equipment Rule

2007-11-04T18:48:00.000-08:00

On September 12th, 2007, amendments to 17 CCR 93116 went into effect for diesel engines that power equipment such as air compressors, portable batch plants, pile-drivers and generators. The changes primarily affect engines greater than 50 HP.

Under the changes, all engines must be federal or California Tier Certified by 1/1/2010 with some exceptions for emergency and low use engines. Alternatively, owners may commit to replacing with Tier 4 engines within 2 years of commercial availability.

Owners of portable equipment fleets must also comply with averaged fleet emission requirements. The initial compliance date is 2013 with additional and more stringent compliance deadlines in 2017 and 2020. There are incentives in the fleet portion of the rule that give extra credit for early use of Tier 4 engines, the use of alternative fuels and electrification of processes that used to be diesel driven.

Owners and operators of portable diesel equipment will need to maintain records of engine operation, and other emission related data. Owners will also be required to submit a signed statement of compliance to CARB before March, 2013 and again before March, 2017 and 2020. Enforcement of this regulation will be a joint effort of CARB and local air districts.

For the text of the full portable equipment air toxics regulation (17 CCR 93116) go to: http://www.arb.ca.gov/portable/perp/peatcm091207.pdf

San Diego APCD Outlines EVR Exemptions for Gas Stations

2007-10-22T16:02:00.000-07:00

The San Diego Air Pollution Control District (APCD) outlined proposed rule changes that would exempt some gasoline dispensing facilities from upcoming requirements to install Phase 2 Enhanced Vapor Recovery Systems (EVR). The proposed rule changes were outlined in a workshop held on October 18th in San Diego.

If the proposed rule changes pass, systems that dispense E85 Gasohol or serve fleets that are at least 95% On-Board Refueling Vapor Recovery (ORVR) equipped can apply for the exemption. Facility operators that wish to take advantage of this program will need to apply for a change in permit conditions and will, as part of the exemption, be required to remove the existing Phase 2 Vapor Recovery System (non-EVR).

The San Diego APCD plans to bring the proposed rule changes to the Board in February of 2008. District staff stated that they expect approval by March of 2008. Applications for the exemptions must be filed by July, 2008 for facilities that dispense more than 600,000 gallons/year and by October of 2008 for facilities that dispense less than 600,000 gallons/year. Facility operators that apply for the exemption will still be required to have and maintain existing Phase 1 EVR systems. This includes maintaining a permit, conducting annual testing and maintaining inspection logs.

What is ORVR?
On-board Refueling Vapor Recovery is a set of components built into a vehicles fuel storage system that prevents the loss of gasoline vapors to the atmosphere during vehicle refueling. Most ORVR systems consist of a charcoal canister that is connected to the vehicle’s fill pipe. If a vehicle is equipped with ORVR, it makes the fuel-site vapor recovery system redundant. ORVR and other vapor recovery systems are not required for diesel fuel.

How can I tell if vehicles in my fleet are ORVR equipped?
The US EPA mandated the phase in of ORVR equipped vehicles starting in 1997. As of 2006 all new gasoline powered on-road vehicles must be ORVR equipped. Below is a table showing the phase in dates for ORVR by vehicle class.

What if I have vehicles that were built during years that ORVR was not required on all vehicles?
The emission sticker under the hood of the vehicle will tell you if the vehicle is ORVR equipped. If the 5th digit of the “EVAP” or “EVAP FAMILY” number is an “E” or “V” the vehicle is not ORVR equipped. If the 5th digit is “R” then the vehicle is ORVR equipped.

Examples of Emission Stickers from draft CARB document:

CARB Proposes On-Road, In-Use, Heavy-Duty Diesel Vehicle Rule to Limit PM and NOx

2007-10-22T15:53:00.000-07:00

California Air Resources Board (CARB) staff are conducting workshops to roll out proposed regulations. The new regulation would affect more than 1.5 million existing buses, trucks and other heavy-duty diesel vehicles operating in California. The proposed rule does have exemptions for private-use vehicles.

Under the proposed rule, fleet operators will have two compliance options: install best available control technology (BACT) on vehicles on before the required compliance date or maintain target fleet emission averages. Link to workshop presentation at CARB website: http://www.arb.ca.gov/msprog/onrdiesel/documents/071017_Truck_%20Reg_Workshop.pdf
For a draft copy of the proposed regulation, go to the CARB website: http://www.arb.ca.gov/msprog/onrdiesel/documents/071015_PROPOSED_ONRD_REG.pdf

The proposed regulation is part of the California Diesel Risk Reduction Program, which was adopted in 2000. The goal of the program is to reduce diesel PMs by 75% in 2010 and by 85% by 2020. This aggressive plan has spawned a host of regulations that will affect nearly every diesel engine operated in the state.

New State Law Will Force the Phase-Out of Older Toxic Dry-Cleaning Chemicals

2007-10-11T09:12:00.000-07:00

As of January 1, 2008, it will be illegal to install new dry-cleaning machines that use perchloroethylene (PERC) as the dry-cleaning solvent. The new regulation will also require the retirement of existing PERC dry-cleaning machines, once they are 15 year old. Thus, all PERC dry cleaning machines should be removed from service by 2023. The regulation has more stringent removal requirements for PERC machines that are operated in a building that is also a residence. These machines must be removed from service by July 1, 2010.

Currently, there are several safer alternative dry-cleaning solvents. These include:
· Water based cleaning
· Carbon dioxide
· Petroleum based solvents
· Methyl siloxane

The most common effects of overexposure to PERC are irritation of the eyes, nose, throat, or skin, and effects on the nervous system similar to the effects of alcohol. PERC causes cancer in laboratory animals at exposure levels close to the level legally allowed in the workplace. PERC is also heavier than water and tends to sink through slab foundations and contaminate ground water.

AQCS secures $144,000 for Diesel Retrofits of Municipal Fleets

2007-09-10T21:48:00.000-07:00

AQCS Environmental authored grants that were funded by the Palomor Energy Mitigation Program through the San Diego APCD. The money will be used to retrofit fourteen heavy-duty on-road diesel vehicles operated by the City of Oceanside and seven heavy-duty on-road diesel vehicles operated by the City of San Marcos. The retrofits will consist of filters designed to reduce particulate emissions (PM) by at least 85%. The $144,000 will be matched by monies from both cities.

Municipal fleets are among the first on-road fleets that must comply with California Air Resource Board regulations that require older dirtier engines to be replaced or retrofitted with particulate traps to reduce PM emissions. Soon, these new regulations, part of the "Diesel Risk Reduction Plan," will also affect private on-road and off-road fleets. The State of California has identified PM as the most significant toxic air contaminant in California; accounting for 70% of the ambient airborne cancer risk. The goal of the Diesel Risk Reduction Plan is to reduce PM emissions by from 28,000 tons/year in 1998 to 7,000 tons/year in 2020; a 75% reduction.

New Diesel Emission Retrofit Database

2007-09-01T23:24:00.001-07:00

AQCS Environmental proudly announces the launch of the Diesel Emission Retrofit Database. This new feature of the AQCS website will allow owners and operators of diesel engines to easily determine what engine retrofits or Diesel Emission Control Systems (DECS) are verified for use on their equipment. California is currently implementing a very aggressive plan to reduce the particulate mater (PM) emitted from diesel engines statewide. Eventually, nearly all pre-2007 diesel engines will need to be replaced or retrofitted with systems that vastly reduce the PM emitted from the tailpipe. Previously, persons wishing to determine what system is verified for a particular engine needed to review dozens of documents listing thousands of EPA engine family numbers. The task was very time consuming and frankly, dreadfully boring. The new database simplifies the process and allows users to choose between looking up by EPA engine family number or conducting a search based on engine manufacturer and year. The engine family search is much more accurate and should be used if the EPA engine family is available. The model/year search gives all of the DECS verified for all engine families of the selected manufacturer for the selected year. However, this is an excellent solution if the engine family is not available or the engine predates EPA engine families.

VST Produces "Balance" EVR System that Misses the Mark

2007-07-31T20:06:00.001-07:00

On July 11th, AQCS Environmental attended a meeting sponsored by Northwest Pump in San Diego California. The primary function of the meeting was to sell EVR upgrade components to gasoline station owners and operators. As part of the meeting, VST, the producer of the only "balance" EVR Phase 2 system that has passed the CARB 180 day performance test gave the audience a preview of the system that should be approved for installation before the end of 2007. We were glad to get the opporitunity to take a look at the system and compare it to the existing Healy system that has already been approved.

The VST system consists of new hanging hardware (nozzles, hoses and breakaways) and a membrane vapor-processor that will control tank-pressure and virtually eliminate vapor losses from the vent pipes. Like other Phase 2 EVR systems, the VST system has the potential to pay for itself in 2-5 years due to the near elimination of inventory losses from the vent pipe. I applaud the effort of VST in producing the first and only balance EVR Phase 2 system that has successfully passed CARB performance tests. However, it appears that in their rush to be first to market, they did not research the market as well as they should have. What is the key element that VST missed? The VST system will only be available with "Exhibit 10" hoses that require the "Liquid Removal Test" . This small detail may entirely undermine the market position VST hoped to gain by being the first balance EVR Phase 2 system to market. Why you ask? The simple answer is "Cost of Ownership"

Balance systems have become very popular in the last four years because they are ORVR compatible, have a small number of moving parts and if configured correctly (as Exhibit 9 or Exhibit 5) can save owners substantial money in testing costs, repair costs, lost operational time and Air District fines. For a typical 36 fueling-point site, I would estimate that Cost-of-Ownership is increased by at least $1800-$2000/year, excluding potential regulatory fines and revenue lost due to down-time during testing.

It is true that the alternative to installing the VST balance system is the Healy Vac-Assist system that requires annual or semi-annual V/L testing. However, this testing can be conducted much more quickly, resulting in less lost revenue to down-time and has a lower failure rate, resulting in lower equipment replacement costs and lower potential regulatory fines.

Overall, the decision by VST to develop a system that requires liquid removal testing has made the choice of whether to go balanc or vac-assist much less obvious. I think it will now come down to cost of installation and owner preference. There is also the potential that other balance systems will be approved in the future that eliminate the need for liquid removal and by installing the VST system now moving to that system will be easier and less expensive. That, however, is speculation and must be weighed by the owners and operators that will be bearing the cost of the upgrade.

What are the top 10 UST Violations in San Diego County?

2007-07-31T20:03:00.000-07:00

Originally Published in May, 2007

The San Diego County Department of Environmental Health held a free UST compliance seminar on May 31, 2007, during which they announced the 10 most commonly cited UST violations:
1. Line leak detectors not functional
2. Monitoring system not functional
3. Dispenser containment not adequately monitored
4. Designated Operator monthly checklist missing or incomplete
5. Certificate of financial responsibility not on site
6. Raised sensors
7. Secondary Containment results not complete or not submitted
8. Audible/Visual alarm not working
9. Unapproved repairs
10. Liquid in sumps

The seminar also included several other presentations on the responsibilities of owners and operators of USTs, significant UST violations and repair permit requirements. AQCS Environmental attends workshops like these to stay current on regulatory requirements and changes in enforcement policy. This is part of our ongoing effort to provide our customers with the best compliance management and consulting available.

City of La Mesa Awarded $290,250 Grant to Replace Older Heavy-Duty Off-Road Vehicles.

2007-07-31T19:59:00.000-07:00

Originally Published in May, 2007

The California Air Resources Board (CARB) awarded the City of La Mesa a $290,250 grant to replace older heavy-duty off-road vehicles with cleaner, less polluting ones. The grant came from a 25 million dollar pool of money authorized by state ballot proposition 1B. The City of La Mesa will replace a backhoe, a loader and a paver with equipment powered by clean Tier 3 diesel engines and are expected to reduce emissions by 2700 pounds over the life of the equipment. The grant will pay for approximately 75% of the cost of replacement. The grant proposal was prepared by AQCS Environmental and included a careful analysis of residual emissions reductions to maximize the competitiveness of the bid.
The funding comes at a good time. CARB is considering a regulation that will require emission reductions from off-road diesel vehicles.

CARB Releases Notification of Requirement to Upgrade Stations Before March, 2009

2007-07-31T19:54:00.000-07:00

From March, 2007

The California Air Resources Board released “Advisory #359” regarding the upcoming deadline for the installation of Phase II EVR systems. The advisory goes on to say: “ Approximately 13,000 GDFs will need to obtain permits, purchase EVR Phase II equipment and arrange for installation by a certified contractor in the next two years. One EVR Phase II system is currently certified (Franklin Fueling/Healy). Franklin Fueling is prepared to meet the equipment demand; however, there is a potential shortage of certified contractors if GDF operators wait too long to install EVR systems.” The advisory also recognized that only one Phase II EVR system has been certified and further states: “Other EVR Phase II systems are under test and could be available by the end of 2007; but there is no guarantee that any system currently in the certification process will successfully complete all performance testing and legal requirements to obtain EVR certification.” The Advisory also emphasized the importance of having a “Certified Vapor Recovery Installer” conduct the installation work.

AQCS is available to discuss EVR installations at your facilities and review contractor certification and installation timelines